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Interoffice Communication
FROM: DATE:
SUBJ:
T. G. Grumbles February 22, 1990
RESPONSIBLE CARE\ENVIRONMENTAL POLICY COMMUNICATIONS
As promised enclosed are the materials for conducting your communication meetings. The basic goal is to complete these efforts by April 1 to assure our employees are informed of our activities prior to CMA's national communication efforts and expected earth day activities.
Enclosed are the following:
1. Copies of the script 2. Overheads (including a hard copy) 3. Feedback cards to be used to start the sessions and at the
end 4. Instructions on use of the feedback cards
Please call me or Mike Reynolds if you have further questions at this time.
T. G. Grumbles
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Distribution: PLANT MANAGERS
R. W. Seymour-Aber, L. R. Bauer-Balt, G, D. Williams-Blane, J. Pavao-Hmd, J. Friend-LCCP, J. W. Ware-LCLAB, R. A. Conrad-LCVCM, H. D. Garrison-Okc, P. L. Foote-Prem, V. W. Weiss-Austin
cc:
w/o attachments T. H. Huffman, J. A. DeBernardi, R. D. Gamblin
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VVV 000011184
TO:
R. D. Gamblin
Interoffice Communication
FROM: DATE:
SUBJ:
T. G. Grumbles February 23, 1990
PROGRESS REPORT
VISTA
1. TGG conducted product liability training sessions with the Legal Department for the BCDP Group, Engineering, and R&D.
2. TGG participated in a meeting of the Vista Product Safety Assessment
Group.
Activities covered included a review of current and future
ethoxylate product testing needs, toxicity data documentation, storage
and retrieval, and finalization of a revised group charter and working
guidelines.
3. Final support packages for Responsible CARE/Environmental Policy communications were distributed this week.
4. A presentation was given to Management on the Clean Water Act and its implications for Vista.
5. Advised LCCP on the applicability of the fugitive emission New Source Performance Standard to the Ethylene Unit.
6. The PVC Drug Master File was revised and submitted to the Food and Drug Administration.
7. The Toxicity Characteristic (TC) is likely to be promulgated in March. Pressure from an environmentalist group, the Environmental Defense Fund, appears to be effective in pushing EPA to publish the final rule. If TC is promulgated in early March, it would become effective in early September.
8. ERT assisted S&T with quality vendor audit at GATX.
9. A visit to Hammond was made to do an assessment of their environmental programs. Preliminary assessment shows no major deficiencies. We will be working with the plant to identify areas of improvement.
10.
MJH is working with Ex-Plant Operations and Customer Service to insure proper non-bulk labeling at all ex-plant packagers.
11.
MJH developed response to conclusions from a recent International Labor Organization Conference on chemical safety/hazard communication for CMA.
CMA is developing an industry response for OSHA.
12.
Bilingual Canadian WHMIS labels were produced and sent to Witco. We are working on the development of WHMIS MSDS's for Canadian customers.
I e-- T. G. Grumbles
VVV 000011195
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EXHIBIT A December 1 , 1989
CHEMICAL MANUFACTURERS ASSOCIATION
MEMBER SELF-EVALUATION FORM
COMMUNITY AWARENESS AND EMERGENCY RESPONSE CODE OF MANAGEMENT PRACTICES
Member Company:
Name:
___________________VISTA CHEMCIAL_____________
Responsible Care Coordinator:
Name:
___________________THOMAS G. GRUMBLES
Address: __________________ p.o. BOX 19029____________
_______________________ HOUSTON, TEXAS 77224
Telephone: ( 713 ) 588-3445 Number of facilities subject to Code
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Community Awareness
1. An ongoing assessment of employee concerns and questions about the facility.
2. Communications training for key facility and company personnel who will connunlcace with employees and the public concerning safety, health and environmental Issues.
.3 Education of employees about the facility's
emergency response plan and safety, health and environmental programs.
4. An ongoing dialogue with employees to respond to their questions and concerns and involve them in community outreach efforts.
.5 Ongoing assessment of community questions
and concerns about the facility.
6. An outreach program to educate responders, government officials, the media, other businesses and the community of the facil ity's emergency response program and risks to the comuaity associated with the facil ity.
7. A continuing dialogue with local citizens to respond to questions and concerns about safety, health, and the environment, and to address other issues of Interest to the covunity.
8. A policy of openness that provides con venient ways for Interested persons to become familiar with the facility, its operations and products, and Ita efforts to protect safety, health and the environment.
.9 A regular evaluation of the effectiveness
of the ongoing employee and community communicationa efforts.
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Emergency Response
1. An ongoing assessment of potential risks to employees and local communities resulting from accidents or other emergencies.
2. A current, written facility emergency response plan which addresses, among other things, communications and the recovery needs of the commit? after an emer gency.
3. An ongoing training program for those employees who have response or communica tions responsibilities in the event of an emergency.
4. Emergency exercises, at leaat annually, to teat operability of the written emergency response plan.
'. Communication of relevant and useful emer gency response planning information to the Local Emergency Planning Committee.
6. Facility tours for all non-employee emer gency responders.
.7 Coordination of the written facility emer
gency response plan with the comprehensive community emergency response plan. If no plan exists, the facility should initiate efforts to create a plan.
8. Participation in the community emergency response planning process to develop and periodically test the comprehensive com munity emergency response plan developed by the Local Emergency Planning Comlttee.
.9 Sharing of Information and experience
relating to emergency response planning, exercises, and the handling of incidents with other facilities in the community.
Motes: Please Identify any specific problems and/or resources.
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Interoffice Communication
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T. G. Grumbles February 26, 1990
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OSHA PROPOSED STANDARD FOR CADMIUM
VISTA
Based on the proposed standard and the significant reductions in the PEL, you should review all data you have for cadmium exposures. I need to know what personal sampling results we have for the last year.
Please give me a call to discuss your sampling and cadmium use in compounding.
T. G. Grumbles
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Distribution:
B. Trego-Aber, G. Lipps-Prem, H. Peirce-Blane, R. Martin-Austin
vvv 000011189
900 Threodneedlu Houston, Texas 77079 (713) 588-3000
P.O. Box 19029 Houston, Texas 77224 Fax (713) 588-3236
February 26, 1990
Larry Kornreich, CIH Director, Environment & Safety ITT Corporation 320 Park Avenue New York, NY 10022
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Dear Larry:
In regards to Richard Waytko's fee increase proposal, I agree with increasing the exhibit space fee but I don't believe a registration fee Increase is justified at this time. Until we increase the length, content, etc. of the conference I think we should keep the fee at $110. I'm not a "hard-liner" on this, but I can't think of justification at this time if asked by a member.
Sincerely,
Thomas G. Grumbles, C.I.H. Environmental Quality Manager
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VVV 000011190